Security & Ecology Agreement

GGPoker SECURITY AND ECOLOGY AGREEMENT (“SEA”)

TABLE OF CONTENTS

PREAMBLE

  1. OVERVIEW
  2. ACTIONS FOR BREACHES OF SEA

BREACHES

  1. USE OF BOTS
  2. USE OF REAL-TIME ASSISTANCE (RTA)
  3. CIRCUMVENTION
  4. ACCOUNT SHARING
  5. GHOSTING
  6. TRESPASSING
  7. ENHANCED ENFORCEMENT OF VIP GAMES
  8. COLLUSION
  9. PREDATORY BEHAVIOR
  10. BUM HUNTING
  11. CHIP-DUMPING
  12. MULTI ACCOUNTING
  13. USE OF VPN/PROXY & REMOTE DESKTOP
  14. THIRD-PARTY TOOLS
  15. RATHOLING
  16. OFFENSIVE CHAT
  17. USER SOLICITATION
  18. OFFENSIVE USER PROFILE

APPENDIX

  1. PRIVACY POLICY
  2. MISCELLANEOUS

Updated: April 14, 2021

PREAMBLE

1. OVERVIEW

1.1. The Security and Ecology Agreement (the ‘SEA’) as upheld by the GGPoker Security Team (“The Security Team”), should be read by you, the End User (the “User”), before playing on GGPoker and the GGPoker Network (“GGPN”). Your decision to play on GGPoker is confirmation of your acceptance of the terms of the SEA.

1.2. GGPoker’s ethos is that a healthy and safe User ecology is paramount to providing enjoyable poker games. To this end, we have implemented several security measures to foster and maintain a healthy ecology and ensure that GGPoker users experience a safe and secure environment. The items outlined below state what is being monitored, how it is being monitored, and any potential actions taken by GGPoker.

​1.3. The SEA may be subject to revision and variation, without prior notice, at any time. Users are expected to be familiar with the SEA before playing on GGPoker.

2. ACTIONS FOR BREACHES OF SEA

2.1. The Security Team’s paramount objective is to provide a safe and healthy poker environment, and we will always aim to educate users at the outset. In the event of a severe breach (or repeated breaches), your account may be locked to allow for an investigation of the alleged breach. While your account is locked, access to your account, log in, gameplay, withdrawal, deposits, or inter-wallet transfers may be restricted.

2.2. Actions which can be taken against Users for confirmed breaches, based on the accumulated information available to us, are one, or a combination of the following:

  1. WARNING: A written notice;
  2. REWARD REMOVAL: Removal/reduction of your promotional rewards;
  3. SUSPENSION: Temporary suspension of your account;
  4. ACCOUNT CLOSURE: Permanent closure of your account;
  5. PERMANENT BAN: Permanent ban from GGPN;
  6. CONFISCATION: Seizure of funds to compensate victims of any prohibited/fraudulent activities (loss of funds due to use of Bots or other 3rd Party Programs, loss of funds owing to Collusion, loss of funds due to Bum Hunting). Seizure of funds may not only include funds in your poker wallet but in your main wallet as well as any pending withdrawals.

2.3. Regarding the results of any investigations, The Security Team’s decisions are final. The Security Team reserves the right to determine whether or not a breach of the SEA has occurred. By agreeing to our SEA, you hereby accept the Security Team’s said right of decision and determination.

BREACHES

3. USE OF BOTS

3.1. A bot plays without human intervention or reduces the requirement of a human to make decisions. A human must decide what action to take and the exact size of any bet or raise. Any tool or service which reads the current game state and gives a user aid on decisions is strictly prohibited. 

3.2. GGPoker’s software package contains certain features designed to detect the use of automated programs that enable gameplay based on Artificial Intelligence. 

3.3. GGPoker’s software may perform any or all of the following scans to detect the use of illicit automated programs and ensure that a “cheat-free” environment is maintained:

  1. Scan of all active software applications while accessing the client.
  2. Scan of all active processes while accessing the client.
  3. Scan of all activities for the potential use of artificial intelligence.

3.4. If our scans reveal a suspicious application or process, our software may scan the associated files to compile a composite mesh (a profile that characterizes the files associated with the application or process) to be matched against profiles for known illicit automated programs

3.5. Actions taken for breaches: PERMANENT BAN, CONFISCATION

4. USE OF REAL-TIME ASSISTANCE (RTA)

4.1. Any decision made at the poker table should be made unassisted, without the aid of any RTA. Only the owner of the account should decide which actions to take and the exact size of any bet or raise.

4.2. Use of any software and/or reference materials that provides advice and/or has an influence on your decision-making in real-time is strictly prohibited

4.3 Prohibited software includes, but is not limited to, GTO solvers, range calculators, and ICM analyzers.

4.4 Prohibited reference materials include, but are not limited to, solutions/solves from simulations, e.g., GTO charts, range calculation, ICM equity, decision trees, Nash equilibrium, and push/fold charts.

4.5 The following reference material is allowed:  a basic pre-flop chart that defines starting hands to play from each starting position. Reading materials that take into account stack size, relative positions, or user-defined situations are not permitted.

4.6. Actions taken for breaches: PERMANENT BAN, CONFISCATION

5. CIRCUMVENTION

5.1. GGPoker prohibits users from making fraudulent or unlawful use of their software.

5.2. GGPoker prohibits users from breaking into, accessing, or attempting to break into the software and/or GGPN with malicious intent.

5.3. GGPoker prohibits users from exploiting or attempting to exploit software bugs within the client for personal/mutual gain.

5.4. GGPoker has developed and employs sophisticated proprietary technology intended to seek out and identify offending users.

5.5. Actions taken for breaches: PERMANENT BAN, CONFISCATION

6. ACCOUNT SHARING

6.1. GGPN prohibits the sharing of accounts. Users may only access accounts registered by themselves.

6.2. GGPN prohibits sharing a significant volume of hands/results with anyone else to analyze or hunt other users.

6.3. GGPN prohibits sharing accounts as it affects the integrity of leaderboards and promotions.

6.4. Actions taken for breaches: REWARD REMOVAL, PERMANENT BAN, CONFISCATION

7. GHOSTING

7.1 Users are strictly prohibited from playing on behalf of someone else or allowing someone else to play on their account.

7.2 The use of software to share hole card information with other individuals in real-time is strictly prohibited. Further discussed in section 15. Use of VPN, Proxy & Remote Desktop

7.3. Actions taken for breaches: PERMANENT BAN, CONFISCATION

8. TRESPASSING

8.1. GGPN strictly prohibits Users previously banned from any GGPN skin from returning on any GGPN skin account. 

8.2. Actions taken for breaches: CONFISCATION

9. ENHANCED ENFORCEMENT OF CASH GAMES

9.1. Users involved in any of the following financial relationships are strictly prohibited from playing at the same VIP cash game tables as their associates: staking, swaps, profit-sharing, or any bankroll sharing agreement.

9.2. Real Name players and players that have been requested to provide personal documents for Real Name conversion are strictly prohibited from creating and/or playing on any new accounts, and creating and/or playing on any pre-existing accounts other than their Real Name accounts, on any GGPN skin.

9.3. Actions taken for breaches: PERMANENT BAN, CONFISCATION

10. COLLUSION

10.1. Collusion is the behavior in which two or more users establish a partnership to gain an unfair advantage over other users at the same cash game table or same tournament. The Security Team’s general rules regarding collusion are (but not limited to):

  1. Users’ hands must be played independently, in their own best interests.
  2. Users must not have a partnership to gain an advantage over other users.
  3. Users must refrain from “Soft-Play,” i.e., the act of intentionally playing hands in a non-aggressive manner against another user who is either a friend, backer, or another person of interest. The only exception to this Rule 3 is the “In The Money (ITM)” bubble and multi-handed situations past the money bubble in which one or more users is all-in.
  4. Users must not share hole-card information with another user under any circumstances.

10.2. The Security Team employs sophisticated industry-leading tools to detect suspicious actions deemed as collusion. Our tools monitor an assortment of data, such as hand history, betting patterns, and user gameplay. We also look at various other sources of information as part of our investigations.

10.3. Actions taken for minor breaches: WARNING, TEMPORARY BAN 

10.4. Actions taken for repeat/major breaches: PERMANENT BAN, CONFISCATION

11. PREDATORY BEHAVIOR

11.1. Predatory Behavior is defined as user activities focused primarily on engaging in unethical advantages and tactics to exploit other users to gain unfair profit. 

11.2. Predatory Behaviour includes, but is not limited to, Bum Hunting, Collusion, Use of Artificial Intelligence, Ratholing, Grimming, Hit-and-running, Buttoning, and other behaviors deemed unethical by consensus of the poker community). 

11.3. GGPoker’s promise to its users is to provide a safe, fun, and enjoyable poker environment. Predatory Behavior is in direct conflict with our promise, and as such, the Security Team adopts a strict zero-tolerance policy.

11.4. Actions taken for initial breaches: WARNING, TEMPORARY BAN 

11.5 Actions taken for repeat breaches: PERMANENT BAN, CONFISCATION

12. BUM HUNTING

12.1. Bum hunting is defined as the act of deliberately targeting one subset of (usually weaker) Users while avoiding giving action to another subset of (usually stronger) Users.

12.2. Bum hunting includes targeting a User by intentionally sitting out at a table or observing Cash Game tables and only participating when the preferred User joins.

12.3. Bum hunting also includes the act of purposely targeting a User by following the targeted User’s activity. For example, being on standby in the lobby until a preferred User enters a game and then following them into the game and playing only until said User leaves. 

12.4. While it is acceptable to be seated and occasionally deny action in certain circumstances, giving action to certain players while denying action to other players when you are starting tables is strictly prohibited.

12.5. Queueing, the act of intentionally seeking to avoid playing against specific players in blind registration games, such as Spin & Gold, is strictly prohibited.

12.6. Actions taken for initial breaches: WARNING, TEMPORARY BAN 

12.7. Actions taken for repeat breaches: PERMANENT BAN, CONFISCATION

13. CHIP-DUMPING

13.1. Chip-dumping is defined as the act of a user intentionally losing his/her chips to another user.

13.2 Actions taken for minor breaches: WARNING, TEMPORARY BAN 

13.3. Actions taken for repeat/major breaches: PERMANENT BAN, CONFISCATION

14. MULTI ACCOUNTING

14.1. GGPN prohibits users from intentionally opening/using multiple accounts on the same GGPN skin.

14.2. GGPN prohibits users from playing from multiple accounts simultaneously. This includes, but is not limited to,  playing on the same Cash Game table, Spin&Gold game, or the same player pool for any other games offered.

14.3. GGPN prohibits users from playing from multiple accounts in the same tournament. 

14.4. GGPN prohibits users registering for the same tournament multiple times to take advantage of freerolls or promotions.

14.5. If a user accidentally creates a multi-account, we will close all newly created accounts and move funds to the original account.

14.6. Actions taken for breaches: ACCOUNT CLOSURE, PERMANENT BAN

15. USE OF VPN, PROXY & REMOTE DESKTOP

15.1. GGPoker strictly prohibits users located in prohibited jurisdictions to use VPN/PROXY, remote desktops, or any alternative methods to mask their actual location.

15.2. Should we determine that users are accessing GGPoker from prohibited countries, we may restrict their use of VPN/Proxy, or suspend the account and request Proof of Presence (“POP”).

15.3. GGPoker also strictly prohibits the use of remote desktop and screen-sharing software while accessing the GGPoker client, as they can be used to facilitate breaches of our SEA, including playing from prohibited countries, ghosting, multi-accounting, RTA, and botting.

15.4 Actions taken for minor breaches: WARNING, TEMPORARY BAN 

15.5 Actions taken for repeat/major breaches: PERMANENT BAN, CONFISCATION

​16. THIRD-PARTY TOOLS

16.1. GGPoker does not permit the use of certain third-party tools.

16.2. A third-party tool is prohibited if it

  1. Datamines: (i) hands or private results (observing games without playing to build up a database of hand histories for future reference) and (ii) the mass sharing of hands, personal results, or playing statistics for analysis of opponents.
  2. is a Heads-Up Display (HUD), i.e., a program that displays users’ past tendencies and betting patterns.
  3. assists in automatic seating or game-selection efficiency.
  4. is deemed by The Security Team to provide an unfair advantage over other users.

16.3. A third-party tool is permitted if it

  1. assists only in the tiling/aligning of tables.
  2. assists in creating macros and hotkey for gameplay efficiency that does not reduce the requirement of a user having to make a decision. The user must decide what action to take and the exact relative size of any bet or raise, with the macro or hotkey merely executing it. For example, a hotkey that bets half the pot is permitted. A hotkey that bets a randomized amount between half and three-quarters of the pot is prohibited.
  3. is deemed inoperable in conjunction with the client, despite exhibiting characteristics of prohibited third-party tools.

16.4. Actions taken for minor breaches: WARNING, TEMPORARY BAN 

16.5. Actions taken for major/repeat breaches: PERMANENT BAN

17. RATHOLING

17.1. Ratholing includes, without limitation, incidents where a user plays short-stacked, and upon hitting a certain chip threshold, the offending user intentionally leaves the table and immediately sits with a lesser stack at a new table of the same limit.

17.2. Actions taken for breaches: WARNING, TEMPORARY BAN 

18. OFFENSIVE CHAT

18.1. GGPoker expects users to follow the rules of common decency concerning table chat.

18.2. Foul/Abusive Language: Users found using foul and/or abusive language will be issued a warning and have their chat removed for seven (7) days. Repeated offenses from the same user may result in an extended suspension or a lifetime ban from GGPN.

18.3. Racist Language: Users found using racist language will be issued a warning and have their chat removed for a month. A second offense will result in the permanent removal of said user’s chat function.

18.4. Spamming: Users found spamming other users about external websites, promotions, or products will have their chat function removed permanently.

18.5. Begging: Users found begging at the tables will be given a warning and have their chat removed for a month. A second offense may result in the removal of said user’s chat function.

18.6. Discussing Hands-in-play: Users found discussing hands-in-play will have their chat function removed for a month. Repeated offenses may result in the permanent removal of said user’s chat function.

18.7 Coordinating group actions:  Users found coordinating group actions will have their chat function removed for a week. Repeated offenses may result in the permanent removal of said user’s chat function.

18.8. Should GGPoker disable the chat function from a user’s account, a message detailing the reason for the removal will be issued to said user.

18.9. Actions taken for initial breach: WARNING, TEMPORARY CHAT BAN

18.10. Actions taken for repeat breaches: PERMANENT CHAT BAN

19. USER SOLICITATION

19.1. GGPoker considers any attempts to solicit personal information as a threat to our users, and strictly prohibits such behavior. Should GGPoker determine that solicitation of personal information has occurred, we reserve the right to immediately suspend the offending accounts for further investigation, permanently ban the offending accounts, and in severe cases, take legal actions against these accounts.

19.2. Actions taken for initial breach: WARNING, TEMPORARY CHAT BAN

19.3. Actions taken for repeat breaches: PERMANENT CHAT BAN, PERMANENT BAN

20. OFFENSIVE USER PROFILE

20.1. Users should not have user profiles, i.e., nicknames and avatars, that are offensive to other users. A common-sense policy should be used to determine what is deemed to be offensive. Examples are user profiles with expletives, insults, political, racial, or sexual implications, and celebrity impersonations.

20.2. GGPoker reserves the right, without prior notice, to replace any avatars it deems to be offensive.

20.3. GGPoker reserves the right, without prior notice, to reset any Nicknames it deems necessary.

20.4. Users that continuously update offensive user profiles can lose access to these functions.

20.5. Actions taken for breaches: WARNING, TEMPORARY BAN

APPENDIX

21. PRIVACY POLICY

21.1. GGPoker is committed to protecting users’ personal information. The Privacy Policy describes what information we collect, why we collect this information, and how we use it.

21.2. We may automatically collect specific data and receive Personal Information that the user provides to us. We may also receive Personal Information from operators and service providers. We will have access to any information that the user provides to such vendors, service providers, and third-party e-commerce services. We will use the Personal Information as set out in this Privacy Policy. We take steps to ensure that our arrangements with third-party service providers and online vendors protect our user’s privacy.

21.3. We may disclose your Personal Information if required to do so by law, or for the reasons outlined below:

  1. to comply with any legal process served on us, any of our sites, or the Services or circumstances under a substantially similar legal obligation.
  2. to protect and defend our rights or property.
  3. if, in our reasonable judgment, it is necessary to enforce compliance with our internal policies to protect our company, customers, or others.
  4. where sharing or disclosing your information is required to offer you products or services you desire, provided that the user has given us his/her consent to do so.

21.4. We may disclose your information to the following:

  1. to a third-party or parties, where disclosure is required or permitted by law.
  2. to any other entity that acquires all or a portion of our organization by merger, reorganization, operation of law, or a sale of some or all of our assets.

21.5. For Security Investigation purposes, we may look to determine whether prohibited tools or software are running on your computer, however, we do not scan your internet browsing history, documents or other such private files.

22. MISCELLANEOUS

22.1. Users determined to have breached multiple SEA rules may face actions in addition to those corresponding to each respective violation.

22.2. Warnings and penalties issued to a user will apply to all accounts belonging to the user, regardless of GGPN skin.

22.3. If a user avoids or fails to cooperate with our investigations, GGPoker will have no choice but to rely on its investigation findings to draw conclusions and administer penalties (as set out in Provision 2. ACTIONS FOR BREACH OF GGPOKER SEA).

22.4. GGPoker reserves the right to refrain from revealing details about how security investigations have been conducted not to fall susceptible to future abuse and circumvention of our detection methods.

22.5. GGPoker shall ensure a high standard of regulatory compliance concerning preventing its services from being associated with crime and disorder. GGPoker shall implement appropriate safeguards to minimize the risk of its gaming platform being used to launder money, assisting in the financing of terrorism, or being a victim of a crime. GGPoker shall ensure that management and staff are aware of their obligations at law and procedures that must be followed.